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Inc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the d
fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, at best, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion withou
nc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the d
re relaxed pleading standards set forth by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007) and Ashcroft v. Igbal, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As explained and applied by the Second Circuit:
Inc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the d
fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion. As described i
Entities connected to both Schlaifer Nance & Co. and Igbal

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Michael Cohen
PERSONAce Greenberg
PERSON
Andy Warhol
PERSON
Ashcroft
PERSON
New York
LOCATIONTwombly
PERSONSecond Circuit
ORGANIZATIONBell Atlantic Corp.
ORGANIZATIONthe Southern District
LOCATIONO'Brien
PERSONthe Upper East Side
LOCATIONAbarca
PERSONMorgan Stanley & Co.
ORGANIZATIONCamofi
PERSONThe Court Does Not Have Jurisdiction Over Defendants
ORGANIZATIONWood v. Research Applied Associates
ORGANIZATION